Cuay Global, LLC (“Cuay Global”) Privacy Statement
What information Cuay Global collects and why
Information from website browsers:
If you're just browsing the website, Scrolls of Legacy, we collect the same basic information that most websites collect. We use common internet technologies, such as cookies and web server logs. This is information we collect from everybody, whether they have an account or not.
The information we collect about all visitors to our website includes the visitor’s browser type, language preference, referring site, additional websites requested, and the date and time of each visitor request. We also collect potentially personally-identifying information like Internet Protocol (IP) addresses.
Why we collect this information:
We collect this information to better understand how our website visitors use Scrolls of Legacy, and to monitor and protect the security of the website.
Information from users with accounts
If you create an account, we require some basic information at the time of account creation. You will create your own user name and password, and we will ask you for a valid email address. You also have the option to give us more information if you want to, and this may include "User Personal Information."
"User Personal Information" is any information about one of our users which could, alone or together with other information, personally identify him or her. Information such as a user name and password, an email address, a real name, and a photograph are examples of “User Personal Information.” User Personal Information includes Personal Data as defined in the General Data Protection Regulation.
User Personal Information does not include aggregated, non-personally identifying information. We may use aggregated, non-personally identifying information to operate, improve, and optimize our website and service.
Why we collect this information
We need your User Personal Information to create your account, and to provide the services you request, or to respond to support requests.
Our legal basis for processing information
- We use your User Personal Information, specifically your user name, to identify you on Scrolls of Legacy.
- We use it to fill out your profile and share that profile with other users.
- We will use your email address to communicate with you.
- We use your User Personal Information for internal purposes, such as to maintain logs for security reasons, for training purposes, and for legal documentation.
- We limit our use of your User Personal Information to the purposes listed in this Privacy Statement. If we need to use your User Personal Information for other purposes, we will ask your permission first.
Under certain international laws (including GDPR), Cuay Global is required to notify you about the legal basis on which we process User Personal Information. Cuay Global processes User Personal Information on the following legal bases:
When you create a Scrolls of Legacy account, you provide your user name and an email address. We require those data elements for you to enter into the Terms of Service agreement with us, and we process those elements on the basis of performing that contract. Cuay Global does not collect or process a credit card number, but our third-party payment processor does.
When you fill out the information in your user profile, you have the option to provide User Personal Information such as your full name, birthplace, gender, high school, college, occupation, and employer. We process this information on the basis of consent. All of this information is entirely optional, and you have the ability to access, modify, and delete it at any time.
Generally, the remainder of the processing of personal information we perform is necessary for the purposes of our legitimate interests.
What information Cuay Global does not collect
We do not intentionally collect sensitive personal information, such as social security numbers, genetic data, health information, or religious information. Although Cuay Global does not request or intentionally collect any sensitive personal information, we realize that you might store this kind of information in your account, such as in a “bond” repository. If you store any sensitive personal information on our servers, you are responsible for complying with any regulatory controls regarding that data.
We do not intentionally collect User Personal Information that is stored in your private “bond” repositories. Information you post in your “bond” repositories belongs to you, and you are responsible for it, as well as for making sure that your content complies with our Terms of Service. Any personal information within a user's repository is the responsibility of the repository owner.
“Bond” repository contents
Cuay Global employees do not have access to information inside private “bond” repositories.
If you choose to post content to the “public archives” repository, anyone (including us and unaffiliated third parties) may view its contents. If you have included private or sensitive information in the “public archives” repository, such as email addresses or passwords, that information may be indexed by search engines or used by third parties.
How we share the information we collect
- We do share User Personal Information internally for marketing and other similar purposes.
- We do not share, sell, rent, or trade User Personal Information with third parties for their commercial purposes.
- We do not host advertising on Scrolls of Legacy.
We do not disclose User Personal Information except in the following situations:
Cuay Global may disclose personally-identifying information or other information we collect about you to law enforcement in response to a valid subpoena, court order, warrant, or similar government order, or when we believe in good faith that disclosure is reasonably necessary to protect our property or rights, or those of third parties or the public at large. In complying with court orders and similar legal processes, Cuay Global strives for transparency. When permitted, we will make a reasonable effort to notify users of any disclosure of their information, unless we are prohibited by law or court order from doing so, or in rare, exigent circumstances.
We may share User Personal Information if we are involved in a merger, sale, or acquisition. If any such change of ownership happens, we will ensure that it is under terms that preserve the confidentiality of User Personal Information, and we will notify you on our website or by email before any transfer of your User Personal Information. The organization receiving any User Personal Information will have to honor any promises we have made in our Privacy Statement or in our Terms of Service.
How you can access and control the information we collect
If you’re already a Scrolls of Legacy user, you may access, update, alter, or delete your profile information by editing your user profile.
Data retention and deletion of data
Generally, Cuay Global will retain User Personal Information for as long as your account is active or suspended or as needed to provide you services.
We may retain certain User Personal Information indefinitely, unless you delete it or request its deletion. If you would like to cancel your account or delete your User Personal Information, you may do so in your user profile. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, but barring legal requirements, we will delete your full profile within ninety (90) days.
After an account has been deleted, certain data, such as contributions or content published in private “bond” repositories, or in the “public archives” repository, will remain indefinitely. The user name you have supplied will be associated with any content you publish.
How Cuay Global secures your information
Cuay Global takes all measures reasonably necessary to protect User Personal Information from unauthorized access, alteration, or destruction; maintain data accuracy; and help ensure the appropriate use of User Personal Information. In the event of a data breach that affects your User Personal Information, we will act promptly to mitigate the impact of a breach and notify any affected users without undue delay.
Transmission of data on Cuay Global is encrypted using SSH, HTTPS, and SSL/TLS. While our data is not encrypted at rest, we manage our own cages and racks at top-tier data centers with excellent physical and network security, and when data is stored with a third party storage provider, it is encrypted.
No method of transmission, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.
Cuay Global’s global privacy practices
We store and process the information that we collect in the United States in in accordance with this Privacy Statement (our subprocessors may store and process data outside the United States). However, we understand that we have users from different countries and regions with different privacy expectations, and we try to meet those needs even when the United States does not have the same privacy framework as other countries'.
We provide the same standard of privacy protection, as described in this Privacy Statement, to all our users around the world, regardless of their country of origin or location, and we are proud of the levels of notice, choice, accountability, security, data integrity, access, and recourse we provide.
Changes to our Privacy Statement
Although most changes are likely to be minor Cuay Global may change our Privacy Statement from time to time. We will provide notification to Users of material changes to this Privacy Statement through our Website at least 30 days prior to the change taking effect by posting a notice on our home page or sending email to the primary email address specified in your Scrolls of Legacy account.